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Code Section 754: Allocating Gain Where it Belongs

Our Recommended Reading List on Tax Policy

Nothing to Fear but Fear Itself: Planning in the Current Environment
Final Subpart F Regulations and Domestic Partnership Tax Reporting
A Year in Review and an Outlook on the Horizon for Tax-Exempt Entities

Latest Articles

  • IRC Section 163(j) Update, Including Highlights of CARES Act Modifications and IRS Final Regulations

    By:
    Edward P. Rigby, CPA, MST
    |
    Feb 1, 2021
    This article summarizes the key highlights of the Coronavirus Aid,  Relief, and Economic Security (CARES) Act modifications and recent IRS regulations associated with the interest expense limitation rules under IRC Section 163(j). In general, the interest expense limitation rules under Section 163(j) were enacted as part of the Tax Cuts and Jobs Act (TCJA), effective for tax years beginning after December 31, 2017. 

  • Tax Issues in Divorce: Before and After Tax Reform

    By:
    Justin T. Miller, J.D., LL.M., TEP, AEP®, CFP®
    |
    Feb 1, 2021

    This is a three-part piece focusing on tax issues in divorce before and after tax reform. Stay tuned for pieces in the February and March issues, which will be discussing many other aspects including dependency exemptions and child tax credits, sale of principal residence exclusion, deductions related to divorce, support trusts in lieu of alimony and more.

  • The SECURE Act: Increased Income Taxes on Inherited Retirement Accounts

    By:
    Nicholas S. Proukou, Esq.
    |
    Feb 1, 2021
    The Setting Every Community Up for Retirement Enhancement (SECURE) Act accelerated income taxation on inherited retirement accounts dramatically. This was huge news for the estate and financial planning worlds in early 2020—until it wasn't. This past year was full of strange and dramatic turns, many of which have overshadowed this seismic shift in retirement account taxation under the SECURE Act.

  • America, Love It or Leave It!: Tax Consequences of Citizenship Renunciation

    By:
    Alicea Castellanos, CPA
    |
    Feb 1, 2021
    During the tumultuous protests against the Vietnam War in the late ’60 s and ’70s, many pro-war activists decried the slogan “America, love it or leave It!” The meaning behind the slogan is that there is no middle road when proclaiming allegiance and loyalty to the United States—that is, you are either supportive of your country and the decisions made by its government, or if not, you have the choice to live elsewhere. It is a highly emotional proclamation reminiscent of a time in this country when people were deeply divided on life-and-death issues. 

  • SALT Business: A Glimpse in the Eye of the Pandemic

    By:
    Timothy P. Noonan, JD and Doran J. Gittelman
    |
    Jan 1, 2021
    There has been no shortage of excitement in the State and Local Tax (SALT) world this year. Between state-issued COVID-19 guidance, federal stimulus efforts, and the ever-changing landscape of income sourcing and nexus rules, individuals and multistate businesses are struggling to remain tax compliant. In this article, we will focus on some of the hot topics in state and local tax this year, and touch upon some of the big shifts occurring during the pandemic. 

  • PPP Loan Forgiveness Update

    By:
    Stewart Berger, CPA
    |
    Jan 1, 2021
    In response to COVID-19, the Coronavirus Aid, Relief and Economic Security (CARES) Act was enacted whereby Paycheck Protection Program (PPP) e-loans made from February 15, 2020 to August 8, 2020 may be forgiven. The cancelled debt will be excluded from income under Reg. 1.265.1. Taxpayers cannot deduct expenses that are allocable to income, whether they are excluded from income or exempt from taxes. The IRS has previously determined that businesses whose PPP loans are forgiven cannot deduct business expenses paid for by the loan.

  • New York Issues Guidance on How to Report the Decoupling from the CARES Act on the Personal Income on Tax Forms IT-201, IT-203, IT-204 and IT-205

    By:
    Mark H. Levin, CPA, MS (taxation)
    |
    Jan 1, 2021

    Ever since New York decoupled from the Coronavirus Aid, Relief, and Economic Security (CARES) Act in the 2020/21 Budget Act, tax practitioners have been asking how one reports a taxpayer’s income as required under the decoupling. This confusion arose because when the decoupling was enacted, no new Tax Law §§ 612(b) additions & 612(c) subtractions were enacted. However on Forms IT-201, IT-203, IT-204 and IT-205, taxpayers are still required to list the taxable items that comprise their taxable Federal adjusted gross income (AGI). Due to the decoupling from the CARES Act, these items may not be the same for New York.

  • Cannabis Tax Update

    By:
    John V. Pellitteri, CPA
    |
    Jan 1, 2021

    There are many factors that set the cannabis industry apart from other business sectors–chief among them, the unique tax treatment that puts cannabis business owners at a distinct financial disadvantage to their counterparts in other industries.

  • Non-Qualified Deferred Compensation as an Employee Retention Tool

    By:
    Joshua P. Friedlander, Matthew E. Rappaport, JD, Esq., LL.M., and Daniel P. Knudsen, Esq., LL.M.
    |
    Dec 1, 2020
    Even in a labor market and greater economy ravaged by coronavirus disease (COVID-19), good help is still hard to find.  Business owners might be focusing on how to navigate the pandemic and keep the company alive, but the threat of a competitor poaching an enterprise’s best people looms in the background.  Small businesses are particularly vulnerable to losing their best people because a larger competitor could offer a lucrative package to entice even the most loyal employee to jump ship.

  • A Tale of Two Citizenships: Taxation of American Citizens with Dual Citizenship Living Abroad

    By:
    Alicea Castellanos, CPA
    |
    Dec 1, 2020
    According to a recent New York Times article, the current pandemic in the United States has created an uptick in the number of citizens applying for dual citizenship in other areas of the world. With a focus on Europe, the author of the article notes that the laws for obtaining citizenship in European countries are favorable to those descended even several generations from their original ancestor immigrants.

Page

Tax Cases


In Case You Missed It – May 2023
Tax Jokes
  

Which Avenger pays the least taxes? Spider-Man, because his income is all net.

https://parade.com/1317763/jessicasager/accounting-jokes/

Tax News


IRS, Other Agencies Issue COVID-19 FAQs in Response to Impending End of Public Health Emergency,The Trusted Professional

Tax Court Rules IRS Does Not Have Statutory Authority to Assess Penalties for Failure to File Form 5471,Forbes Media LLC

IRS Revises Guidance on Bitcoin, in Light of Its Use As Legal Tender in Some Nations,The Trusted Professional

Hight Court Considering Case on Whether IRS Can Secretly Obtain Bank Records of Taxpayer's Relatives,The Trusted Professional

More Foreign Companies Than Expected May Be Subject to 1% Buyback Tax,The Trusted Professional

After Beyoncé Failed to Work It Out With IRS, She Filed A Petition in Tax Court,Forbes Media LLC

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.